MATTER 27: The optional national technical Standard for Water Efficiency Written Statement Affinity Water Limited and Anglian Water Services Ltd ...

North Hertfordshire Local Plan (2011-2036)
                  Examination

MATTER 27: The optional national technical
     Standard for Water Efficiency

            Written Statement

        Affinity Water Limited and
       Anglian Water Services Ltd

                 February 2020

27.1 Through Policies SP9 and D1, the Local Plan seeks to require adherence to
the Government’s optional national technical standards for water efficiency and
the nationally-described internal space standards for dwellings. As you know,
for such policies to be sound, they must be supported by clear evidence of need
and evidence that viability has been considered. In relation to both:

           a) Is the evidence of need adequate/sufficiently robust?
           b) Has viability been properly considered??

All new dwellings have to meet the mandatory national standard set out in the Building
Regulations (of 125 litres/person/day). Where there is a clear local need, local planning
authorities can set out Local Plan policies requiring new dwellings to meet the tighter
Building Regulations optional requirement of 110 litres/person/day.

The National Planning Policy Framework policies expect local planning authorities to
adopt proactive strategies to adapt to climate change that take full account of water
supply and demand considerations. The local planning authority can consider whether a
tighter water efficiency requirement for new homes is justified to help manage demand.

To include the optional higher target, national planning practice guidance states that it
will be for a local planning authority to establish a clear need based on:

     existing sources of evidence
     locally specific evidence including water cycle studies.
     consultations with the local water and sewerage company, the Environment Agency
      and catchment partnerships.
     consideration of the impact on viability and housing supply of such a requirement.

Existing sources of evidence

The main source of information for establishing need is the Environment Agency ‘Water
Stressed Areas Final Classification (2013)’1, which identifies areas of serious water stress
where household demand for water is (or likely to be) a high proportion of the current
effective rainfall available to meet that demand.

The Environment Agency advises the Secretary of State that the areas classified as
'Serious' in the final classification table should be designated as 'Areas of serious water
stress'. Affinity Water the incumbent water company for the District and the neighbouring
Anglian Water region is identified as an area of serious water stress. There is an existing
water transfer from Grafham reservoir in the Anglian Water region into the Affinity Water
area (Hertfordshire).

1
    https://www.gov.uk/government/publications/water-stressed-areas-2013-classification

Furthermore, in 2019, DEFRA launched a consultation called “Measures to reduce
personal water use2”. UK national average water use is 141 litres per person per day
which is higher than other European countries such as Germany -121 litres per person
per day. Said consultation raised questions around setting a per capita consumption
target (which has already been set by OFWAT to all water companies), modification of
the Building Regulations relating to water efficiency, Water Labelling, etc. We expect
DEFRA to announce further details later on this year.

The Environmental Bill 2020 3, published on the 30 January 2020, and highlights that:
“There is more to be done. Our changing climate is associated with more extreme
weather; higher risks of drought and an increase in flooding which seriously affects
people’s lives and assets”. It is clear that Government recognises the future challenges
our society will need to overcome. Water is a finite resource and this Bill stresses the
importance that water plays in people’s lives and the environment as a whole.

Finally, the Environment Agency is working on a Water Resources National Framework
which will be published later on this year. In this first draft it emphasises that: “I3,435
million extra litres of water per day will be needed for public water supply to address
future pressures and around 50% of the national need is in the Southeast”. Regional
plans will be required to reduce demand – to 110 litres of water per person per day by
2050 and drive down water use across all sectors.

In relation to Water Resources Management Plans (WRMP):, Anglian Water’s Water
Resource Management Plan 20194 identifies how Anglian Water will manage the supply
and demand balance over the next 25 years. It shows what demand and supply
measures will be introduced to manage the longer term challenge of population increase,
climate change, drought resilience and growing environmental needs. It is currently
forecasted that our average supply-demand balance will be 249Ml/d by 2045. In
response, reducing the levels of consumption will help to counteract the reduction in
resource availability as well as other proactive alterations.

2
  https://consult.defra.gov.uk/water/measures-to-reduce-personal-water-use/
3
  https://publications.parliament.uk/pa/bills/cbill/58-01/0009/20009.pdf
4
  https://www.anglianwater.co.uk/about-us/our-strategies-and-plans/water-resources-management-plan/

Similarly, Affinity Water’s
                                                                                   WRMP for 2020-2025 sets
                                                                                   out how we will maintain
                                                                                   our supply and demand
                                                                                   balance over the next 60
                                                                                   years (2020 - 2080) and
                                                                                   accounts for population
                                                                                   growth based on local
                                                                                   authority    plans.     The
                                                                                                    5
                                                                                   Central Region presents
                                                                                   the     most    challenging
                                                                                   situation.   This     graph
                                                                                   shows what the scene will
                                                                                   look like if Affinity Water
                                                                                   do nothing.

Increasing water efficiency in new homes would also reduce the amount of foul flows
which are discharged into the public sewerage network managed by Anglian Water. This
would reduce the impact on existing infrastructure.

Consultations with the local water and sewerage company and the Environment Agency

Anglian Water and Affinity Water are of the view that there is sufficient evidence to
justify the inclusion of the optional higher water efficiency standard in the North
Hertfordshire Local Plan.

It is essential to highlight that Affinity Water, after three consecutive years of dry
winters, in 2019 launched a Drought Awareness survey reaching over 500,000 customers
warning them of the possibility of a Temporary Use Water Restriction (known previously
as ‘hosepipe ban’), for its Central region in Spring 2020, if this winter was below rainfall
average.

Viability

Local Planning Authorities are required to consider viability taking account of local
circumstances and policy requirements but Government research has shown that the cost
of the optional higher water efficiency standard and associated cost can be as low as £6-

5
 Bedfordshire, Berkshire, Buckinghamshire, Essex, Hertfordshire, Surrey, the London Boroughs of Harrow and Hillingdon
and parts of the London Boroughs of Barnet, Brent,
Ealing and Enfield.

96 per dwelling. We therefore consider that this does not make the North Hertfordshire
Local Plan, or individual development proposals, unviable.

For the reasons set above, we would like to recommend to the Planning Inspectorate to
find North Hertfordshire Local Plan Water Efficiency policies ‘sound’ and that these can be
adopted by the District Council.

6
    The Housing Standards Review Cost Impact report (2014) prepared for DCLG advises that the cost of introducing such a standard
would be between £6-£9 per dwelling.